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                  Section 6662 imposes a penalty equal to 20 percent of               
             any portion of an underpayment of tax that is attributable               
             to negligence or disregard of rules or regulations.  See                 
             sec. 6662(a) and (b).  The term "negligence" is defined as               
             "any failure to make a reasonable attempt to comply with                 
             the provisions of [the Internal Revenue Code]".  Sec.                    
             6662(c).  This includes any failure to exercise due care or              
             to do what a reasonable and ordinarily prudent person would              
             do under the circumstances.  See Rybak v. Commissioner, 91               
             T.C. 524, 565 (1988); Neely v. Commissioner, 85 T.C. 934,                
             947 (1985).  The term "disregard" includes any careless,                 
             reckless, or intentional disregard.  Sec. 6662(c).                       
             Petitioners bear the burden of proving that respondent's                 
             determination of negligence is erroneous.  See Rule 142(a);              
             Luman v. Commissioner, 79 T.C. 846, 860-861 (1982).                      
                  Under certain circumstances, a taxpayer may avoid the               
             accuracy-related penalty for negligence by showing that he               
             or she acted in reasonable and good faith reliance on the                
             advice of a competent, independent tax professional.  See                
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